PRIVACY POLICY

1. INTRODUCTION

We take our clients data protection seriously and treat data with confidentiality and according to data protection laws. This Privacy Policy informs you about how we processes your personal data in the context of our website at www.estating.com or our web/mobile apps. The controller of the processing of personal data in this context is Estating Property Vault S.A. (Estating). You will find contact details in the imprint on Estating’s website and further below in the Privacy Policy.

The following Privacy Policy explains, which data Estating collects, for which purposes and informs about your rights.

2. DATA

What data do we collect?
Estating may collect the following data:

Personal identification information such as name, email address, phone number, your financial advisor, IP address
Technical information from your visits to our website/apps, such as server log-in data, browser type and version, operating system, URL, hostname, time of visit
Cookie ID
Device Identifier
Any other information relating to you which you may provide to us

How do we collect your data?
You directly provide Estating with most of the data we collect. We collect data and process data when you:

a. Register online
b. Voluntarily when you complete a customer survey, complete a contact form or provide feedback on any of our message boards or via email
c. Use or view our website/app via your browser’s cookies
d. Contact us via social media, e.g. linkedin, Facebook
e. Information about you from other sources, such as your financial advisor, other investors or other users of our services

When you use the website, third parties may collect, store and/or process the information detailed in this Privacy Policy. These third parties are carefully selected to ensure that they, and their related entitites, who may access your information, provide your information with equal protection to that stated in this Privacy Policy and required by applicable privacy laws.

What is the legal basis for collecting, storing and processing personal data?
The legal basis for collecting and using the personal data described in this Privacy Policy depends on the personal data we collect and the specific context in which we collect the information:

● Estating needs to perform a contract with you
● You have given consent to do so
● Estating needs to comply with legal and regulatory obligations
● Processing your personal data is in Estating’s legitimate business interests
● For the establishment, exercise or defence of legal claims or proceedings

How will we use your data?
Estating S.A. collects your data so that we can:

● Maintain website functionality (performance of a contract);
● Securely access your personal account (performance of a contract);
● Maintain the connection to your account during your visit/session (performance of a contract);
● Maintain the connection to your account from one browsing session to the other (consent);
● Remember the choice you have expressed regarding cookies (performance of a contract);
● Keep backups in order to ensure the availability of our website (legitimate interest);
● Provide a contact form and respond to your request (performance of a contract);
● Measure success of marketing campaigns (consent);
● Target better offers to our users (consent);
● Contact you with special offers on other products and services we think you might like, such as newsletters, emails or other electronic communication (consent);
● Detect and prevent fraudulent behaviour (legitimate interest);
● For the establishment, exercise or defense of legal claims (legitimate interest);
● For the purposes of a business reorganisation, transfer, disposal, merger or acquisition (legitimate interest).

We may also send you electronic communications about our products and services based on our legitimate interest to advertise our products and services where you have provided us with your contact details in the context of the sale of similar products and services of ours.

How long will we keep your data?
We keep your data in compliance with GDPR requirements and comply with GDPR removal rules. Legal retention periods are preserved.

Data based on contact forms and emails are stored to enable processing of your questions/comments and follow-up communication. We process the data due to your consent. You may ask to revoke your consent at any time via email. Your provided data will be stored until you request erasure, the purpose for storing the data ceases or you revoke your consent.

You have the right at any time to stop us from contacting you for marketing purposes or giving your data to other Estating entities. If you no longer wish to be contacted for marketing purposes, please unsubscribe using the link in our email.

We will delete user data after account closure. If you want to delete your account, please send an email to data.protection@estating.com

Who we share your personal information with?
We are an international prop/fin/tec company operating entities in a variety of countries. Information that you provide to us may be shared with and processed by any of these entities.

We may also share your personal information with certain trusted third parties in accordance with contractual arrangements in place with them, for example your financial advisor or third parties engaged to provide certain support or IT services, among others:

We are using cloud service providers (Microsoft 365, Amazon Web Services) which are accessible through the Internet for several business processes, e.g. document management, calendar management, email, spreadsheet applications, presentations, video conferences, chats. In this context, personal data may be processed and stored on the service provider’s servers, as far as we process data as described in this policy.

We use the services Google (Universal) Analytics, Google Analytics Remarketing, Google Ads, and the Google Tag Manager. These are services provided by Google LLC (1600 Amphitheatre Parkway Mountain View, CA 94043, USA, “Google”). Google is based in the third country USA, which basically lacks an EU level of protection. Therefore, Standard Contractual Clauses as appropriate safeguards according to Art. 46 GDPR are completed with Google.

You can find more information in the Privacy Policy of Google.

We use HubSpot, a service of HubSpot, Inc., 25 First Street, Combridge, MA 02141 USA (“HubSpot”), for the provision, administration and distribution of our e-mail messaging and for our customer relationship management. Further, HubSpot enables customers and prospective customers to book meetings for demonstrations and consultation with Estating. HubSpot is based in the third country USA, which basically lacks an EU level of protection. With Hubspot, Standard Contractual Clauses are completed as appropriate safeguards according to Art. 46 GDPR.

HubSpot transmits personal data to external service providers in order to offer its services. HubSpot processes personal data in accordance with European privacy standards.

You can find more information regarding privacy in the Privacy Policy of HubSpot.

For marketing purposes, we are active on social media and provide information regarding current news, events and other information which may be of interest to you. If you contact the respective page or account or our company in a social network, we will process the personal data that you provide to us in order to establish or maintain contact with you in this network.

We do not use scripted social media plugins to share data from our Website through social media. Rather, our share buttons only contain a link to the social media (e.g. sharer.php for Facebook). As a result of this, we do not process your personal data in this context. In addition, it is ensured that your personal data such as your (possibly truncated) IP address, whole cookies or other information is only transmitted to the social media and thus possibly also to servers in the USA, if you press the relevant button. This also applies to the links to our social media pages that we have implements on our Website. It is possible that a social media provider can link your visit to our services with your user account.

We have no control over the amount and extent of the personal data which is processed by the providers of the social media if you click on a share button or clock on the respective link and access the social media page. Therefore, we can only inform you to the best of our knowledge. Once you access the social media site, the terms and conditions as well as the privacy policy of each social media provider apply.

For the above-mentioned purposes, we use the following social media (you can find more information in the links to the respective privacy policies included below):

LinkedIn: Website: https://www.linkedin.com;
Data Privacy Policy: https://www.linkedin.com/legal/privacy-policy;
Medium: Website: https://medium.com

Data Privacy Policy: https://policy.medium.com/medium-privacy-policy-f03bf92035c9
Facebook: Website: www.facebook.com
Data Privacy Policy https://www.facebook.com/about/privacy/

Which countries we transfer your personal information to?
In order to provide our services to you we may need to transfer your personal information to locations outside the jurisdiction in which you provide it or where you are viewing the website/apps. This may be a transfer of your information from a location within the European Economic Area (EEA) to outside the EEA, or from outside the EEA to a location within, for example:

We are using standard contractual clauses between Estating entities if we are sharing and processing personal information.

Where our third party services providers (see section “Who we share your personal information with”) process personal data outside the EEA in the course of providing services to us, our written agreement with them will include appropriate measures, usually standard contractual clauses.

3. WHAT ARE YOUR PROTECTION RIGHTS?
We would like to make sure you are fully aware of all of your data protection rights.Every user is entitled to the following:

The right to access – You have the right to obtain confirmation as to whether or not we process personal data relating to you, and, where that is the case, access to the personal data and information about their processing. You have the right to request copies of your personal data, provided that this does not adversely affect the rights and freedoms of others.

The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request to complete information you believe is incomplete.

The right to data portability – If the processing of your personal data is based on your consent or on the performance of a contract that you have with us, you have the right to request that we transfer the data concerned to another organization, where technically possible, or directly to you

The right to erasure – You have the right to request that we erase your personal data, except in certain cases, notably if we need your personal data for compliance with a legal obligation or for the establishment, exercise or defence of legal claims.

The right to restrict processing – You have the right to request that we restrict the processing of your personal data in certain situations, notably where you contest the accuracy of your personal data, for a period enabling us to verify the accuracy of your personal data, or, where you have objected to the processing pending verficiation whether our legitimate grounds override those of you.

The right to object to processing – Where the processing of your personal data is based on the pursuance of a legitimate interest, you have the right to object to us processing of your personal data. In this case, we will no longer process your personal data unless we demonstrate compelling legitimate grounds overriding those of you or if we need your personal data for the establishment, exercise or defence of legal claims. Your right to object is unconditional with regard to the processing of your personal data for direct marketing purposes.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at our email: data.protection@estating.com

4. GENERAL INFORMATION
Privacy policies of other websites

Our website contains links to other third party resources. Our Data Privacy Policy applies only to our website/app, so if you click on a link to another website, you should read their privacy policy.

The content of third-party resources is not under our control, and we are not responsible for the contents of any of websites. The third-party hypertext links presented on this site are provided for your convenience only. The inclusion of any link on this website does not imply any recommendation, approval or endorsement of that site by us.

Chances to our privacy policy

We keep our Privacy Policy under regular review and place any updates on this web page. This Data Privacy Policy was last updated on 20 September 2021.

How to contact us

If you have any questions about our Privacy Policy, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us.

Email us at: data.protection@estating.com

How to contact the appropriate authority

Should you wish to report a complaint or if you feel that we have not addressed your concern in a satisfactory manner, you may contact the Luxembourg data protection supervisory authority Commission nationale pour la protection des données (CNPD)

To contact the CNPD, you may use the form on the CNPD website via the following link or use the contact form here.

The form may be completed online or sent to the CNPD by post to the following address:

Commission nationale pour la protection des données
Service des réclamations
15, Boulevard du Jazz
L-4370 Belvaux